Most Popular Compliance Content
Lost Passbook/CD Affidavit Question
05/12/2019
We are one of those hold-out banks that issue passbooks for CD's. Beginning May 1st we are ceasing that practice and just printing a signature card similar to checking and savings accounts. The Mass Banker's Handbook states that: "If individuals lose their passbooks or certificates of deposit a Lost Passbook/CD affidavit must be completed and signed by all parties named on the account.....". My specific question is, does the use of the term CD certificate mean the signature card, or does it refer to institutions that issue actual "certificates", much, like stock certificates used to be issued?
Verifying Annual State Filings Are Up to Date
05/12/2019
During account opening for a new business customer the branches verify that the required annual filings with the state are up to date. As new accounts are opened for existing business customers a CDD questionnaire is completed for each new account, however the branches are pushing back regarding verifying that annual state filings are up to date. I haven't been able to locate any guidance on whether this is a requirement or a recommended best practice. Can you please advise?
General Rules for Account Agreement Changes
05/05/2019
Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
Check Log Required if Cashiers Check Over 10k?
05/05/2019
If a customer purchases a cashiers check with cash over $10,000 I know the CTR is required, but are we still required to do the check log? I thought the check log register was only for amounts $3,000.00 - $10,000.00.
Account Opening and Selection Notice
05/05/2019
For account opening, my bank requires a separate application, signature card, and Uniform Single-Party or Multi-Party Account Selection Notice. Is there a regulation/law/code that requires all of these to match? While auditing, I noticed POD selection and information missing from an application; however, the beneficiary has been named [properly] on the selection notice. Do I need to have the customer complete a new application?